John Tebbit, industry affairs director at the Construction Products Association, takes a look at the latest revisions to the Building Regulations and wonders whether we might be reaching guidance overload …
It has been said that rules are for the obedience of fools and the guidance of wise men. It could be rephrased to say that if you treat guidance as rules then you are probably not a wise man but a fool. Unfortunately many otherwise intelligent people do tend to treat building regulation guidance as mandatory. It would be helpful if more people would flex their professional muscles and intellect and exercise their judgment, rather than blindly following “the rules”.
To help mere mortals meet the requirements of the Building Regulations, guidance in the shape of the approved documents is provided. Each document covers a specific area ranging from A (structure) through to P (electrical safety). Each is revised, supposedly, every five years, which leads to a change in guidance on one area or another of the regulations every four months or so. This gives designers, contractors and suppliers real difficulties. Couple this with the increasing weight of guidance in these documents – the recently issued Part B fire consultation package is more than 600 pages long – and one has to wonder if we are reaching overload. With extra areas of regulation such as security and sustainability coming along, it is perhaps time to look at ways of revising the guidance.
One can hope that this government will want to look at new ways of doing things, especially in terms of reducing red tape. Although guidance is not usually seen as red tape, if it is viewed by building control and other enforcement agencies as the only way of doing things, it does begin to look that way.
What’s new …
Part B: Fire safety With as many pages as the latest Harry Potter, the Part B consultation package was released on 19 July. The consultation runs until 18 November and the full pack can be downloaded from www.odpm.gov.uk. Guidance has been split into two documents (dwellings and other buildings) but most changes are evolutionary rather than revolutionary. It is interesting that proposed changes have been split into “intend to” and “minded to”, the latter being areas where the ODPM is asking for evidence from stakeholders to see whether changes can be justified.
Many otherwise intelligent people do tend to treat Building Regulation guidance as mandatory
A separate consultation is being held by the Department for Education and Skills on fire safety in schools. This builds on Part B but adds extra requirements for protection of property. With 70% of school fires being started deliberately, specialist guidance is clearly necessary. Details can be found at www.dfes.gov.uk/consultations.
Part L: Energy efficiency Implementation appears to have slipped from the end of this year to April 2006 at the earliest, but details are expected in an announcement by the ODPM in late August. Final approved documents will hopefully be published at the same time to give the industry time to prepare, but this is by no means certain. The calculation tool for dwellings is a revised version of the existing standard assessment procedure, and can be found at http://projects.bre.co.uk/sap2005. The general view is that SAP 2005 is virtually finished.
The situation is far less optimistic with the non-domestic calculation tool, which is still in beta version with the second beta being scheduled for release on 22 August. Details can be found at www.ncm.bre.co.uk. Whether this program can be developed to the point of it being a robust, stable and consistent compliance tool in time is an open question. It is not clear whether a standalone version will be available for users as stated in the site’s FAQ page or whether everyone will have to buy commercial software that uses the calculation core. Whichever it is, all non-domestic designers and manufacturers face a steep learning curve.
British Standard BS 8300 A newly amended standard has been released, including changes to sanitary devices, handrails, door closers and light reflectivity to improve consistency with the Part M access rules. See www.bsi-global.com. It was a cause of considerable confusion to the industry, the enforcement agencies and users when Part M came out with different guidance to the previous BS 8300. The Construction Products Association and several of its members persuaded the ODPM that clarification was needed. However, rather than amend the approved document, the ODPM preferred to use the then upcoming amendment of BS 8300 for the revised guidance. Whether this will work as well as a revised approved document is something that the industry has yet to discover.